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4 <br />George Reed, 17300 Jahant Rd. Clements, CA <br />03/14/2018 <br />SPCC Plan states that intearitv testing will be included in Ian once consult in completed in 2016. <br />J <br />f <br />PR0522199 <br />PHOTO # 13 <br />At p'Ping connections, joints, and seals are inspected to determine their <br />condition and repairs are made as necessary. <br />Liquid level gauges for all tanks are inspected to make sure they are in Proper <br />working condition and readable. <br />Periodic Integrity Testing: <br />Integrity testing, above and beyond the visual inspections described above, is required for <br />all aboveground storage tanks, utilizing a non-destructive shell testing technique in <br />accordance with good engineering practices and in accordance with SP001 standards. <br />Testing is to be performed on a regular schedule as well as when repairs are made to <br />storage containers which may increase the potential for a tank failure. As stated in the <br />SPCC 2002 final rule "testing on a regular schedule" means testing per industry standard <br />or at a frequency sufficient to prevent a discharge. The method has not been prescribed <br />in this plan due to the uncert int to <jvaliabili and cost effectiveness of the testing <br />methods. George Reed, Inc. and ?! Y <br />inspector conduct integrity testing in '.lie orderer prescribed ls lhn the following ave an etable based on <br />the most appropriate for the type of tank and cost effectiveness. The methods for testing <br />may differ based on the type of tank and the brittle tank evaluation. <br />Iirtegrity Testing Schedule <br />Tank testing protocols and scheduling for the facility is being prepared by Fletcher <br />Consultants, Inc, in the month of October, 2016. Once the tank evaluation is completed <br />and a tank testing schedule finalized, this plan will be amended to include the integrity <br />testing schedule as an attachment. <br />8•3.4 Site Security (40 CFR 112.7(8)) <br />1 -he facility is only partially enclosed by a fence which is located near the entrance road to <br />tcjllty. Gates are locked during non-operatinghours. Sec <br />efacility which illuminates the facility to al nw fnr the >�nty lights are also set up throng <br />. <br />Aaron Hang, EHS Page 13 of 13 <br />